On 17 May 2018 the European Commission published the proposal for a regulation on the electronic freight transport information regulation.1 Bitkom would like to thank the Federal Ministry of Transport and Digital Infrastructure (BMVI) for the opportunity to comment on the proposal and would like to elaborate and expand on some aspects.

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on electronic cargo transport information (Text with EEA relevance) {SEC(2018) 231 final} - {SWD(2018) 183 final} - {SWD(2018)

Bitkom welcomes the initiative of the European Commission to digitally recognise electronic freight information within the EU and with third countries. Bitkom agrees with the essence of the proposal, which facilitates the process to take full advantage of the modernisation of mobility as it emphasised in the text, e.g. „It is essential that tomorrow's mobility system is safe, clean and efficient for all EU citizens. The aim is to make European mobility safer and more accessible, European industry more competitive, European jobs more secure, and to be cleaner and better adapted to the imperative of tackling climate change. This will require the full commitment of the EU, Member States and stakeholders, not least in strengthening investments in transport infrastruc-ture.”

In addition to the citizens' mobility systems, goods logistics is vital in the new conceptual design of transport and logistics. The meaningful use of digital technologies will form the basis, which will guarantee resource efficiency as well as economic success.

Bitkom sees the following five core requirements:

1. Bitkom recommends a European Single Windows, in which independent areas of customs clearance (Union Customs Code, UCC) and electronic freight transport in-formation (eFIT) should be harmonised and should be discussed with (see page 5 recital 6).

2. Bitkom proposes the concept of a Federal Platform for the EU in which national customs clearance systems could remain at the centre. Other systems and plat-forms can be grouped around it. At any point, each player has access to the required data and can share it with all relevant stakeholders. Authorities should not only accept digitised information, but also make their own data digitally available to the

different players. However access to critical data should be protected in the interest of the owner.

Not everyone in the supply chain has unrestricted access to all data. Each actor receives and delivers only the relevant data to the authorized actors. Business secrets and current EU and national law remain unaffected.

3. Bitkom recommends EU standards according to a multimodal reference model to include new forms of data ex-change (methods / data formats), which are not known yet.

4. Bitkom proposes the access to exports has to be simplified for small and medium-sized enterprises.

5. An EU-wide integration of existing solutions and consideration of current and future developments, but also about consideration of international approaches (IMO, WSC, UN/CEFACT) should be possible.